Justia Labor & Employment Law Opinion Summaries

The case involves Tracy White, an employee of the Iowa Department of Human Services (DHS), who filed a lawsuit against the State of Iowa and DHS under the Iowa Civil Rights Act (ICRA) alleging a hostile work environment. White's complaints about her supervisor led to his termination, but she remained employed at the agency. The jury awarded her $260,000 for past emotional distress and $530,000 for future emotional distress. The State appealed, arguing that the evidence was insufficient to prove White's hostile work environment claim, that the district court erred by admitting certain evidence and incorrectly instructing the jury, and that the future emotional distress damages were excessive.The district court had denied the State's pretrial motion to exclude certain evidence, referred to as "me too" evidence, as unduly prejudicial. This evidence consisted of reports of alleged discrimination experienced by other employees, which White, as a supervisor, had received and relied on to support her own hostile work environment claim. The State argued that such evidence, of which White was unaware, could not prove that she personally experienced a hostile work environment.The Supreme Court of Iowa agreed with the State, concluding that the harassment White personally experienced was not objectively severe or pervasive enough to alter the terms or conditions of her employment. The court held that the district court erred by denying the State's motion for judgment notwithstanding the verdict (JNOV). The court reversed the judgment for White and remanded the case for entry of an order granting the State's motion for JNOV. View "White v. State" on Justia Law

In the Supreme Court of Iowa, a case involved Bridgestone Americas, Inc., and Old Republic Insurance Company, appellants, against Charles Anderson, appellee. Anderson, an employee of Bridgestone, reported a right shoulder injury and a right arm injury after decades of manual labor. He pursued a workers’ compensation action, which was awarded by the deputy workers’ compensation commissioner and affirmed by the workers’ compensation commissioner. The employer sought judicial review, and the district court affirmed the commissioner’s decision.The employer appealed, posing three questions: whether the injuries were compensable, whether they should be compensated as unscheduled injuries under Iowa Code section 85.34(2)(v), and whether the compensation was calculated correctly. The court concluded that the injuries were compensable but should be classified as scheduled injuries under Iowa Code section 85.34(2), paragraphs (m) and (n), not unscheduled injuries.The court affirmed the district court’s decision in part, reversed in part, and remanded the case for determination of compensation for the employee's scheduled injuries, meaning compensation should be based on the extent to which a body part's function has been impaired, not the employee's loss of earning capacity. View "Bridgestone Americas, Inc. v. Anderson" on Justia Law

In this case, decided by the Supreme Court of Iowa, Justin Loew, an employee of Menard, Inc., appealed the district court's decision that denied his claim for workers' compensation benefits. Loew had previously received benefits for a 20% functional impairment to his lower back caused by a work-related injury in 2015, which had been calculated using the industrial method and resulted in a 30% reduction in his earning capacity. In 2018, Loew suffered a second work-related injury to his lumbar spine which increased his functional impairment to 28%. Under the 2017 changes to the workers' compensation law, Loew's compensation for this injury was to be based solely on his functional impairment, since he returned to work at the same or greater wages. However, the workers' compensation commissioner denied Loew any additional benefits for his second injury, reasoning that Menard was entitled to offset the prior payment based on reduced earning capacity against the new claim for functional impairment.The Supreme Court of Iowa disagreed with the commissioner's reasoning and reversed the district court's judgment. The court held that it was incorrect to offset compensation based on loss of earning capacity (from the first injury) against compensation based on functional impairment (from the second injury), as these are incommensurables. Further, the court found that the commissioner erred in interpreting Iowa Code section 85.34(7) to preclude compensation for Loew's new permanent partial disability, as this statute only limits an employer's liability for preexisting disabilities that have already been compensated. Loew was seeking compensation for a new permanent partial disability, not a preexisting one, hence Menard was liable for this new disability. The court remanded the case back to the commissioner for further proceedings consistent with its opinion. View "Loew v. Menard, Inc." on Justia Law

Marshall Sandlin, a laborer at Mid American Construction LLC, suffered an injury to his left foot during work. After an initial medical examination conducted by a physician chosen by Mid American's insurance carrier, Grinnell Mutual, Sandlin underwent another independent medical examination (IME) by a physician of his choosing. Sandlin sought reimbursement for the full cost of this second examination, as he believed the first examination's evaluation was too low.The Supreme Court of Iowa had to decide whether an amendment to Iowa Code section 85.39(2) in 2017 limited an employee's reimbursement for an IME to only the cost of the impairment rating or included the full cost of the examination. The court held that the employee is eligible for reimbursement of the reasonable cost of the full examination to determine the impairment rating, not merely the cost of the impairment rating itself. The court interpreted the term "examination" as used in the statute to include review of medical records, physical examination, testing, and written report.However, the court found that the commissioner's analysis of the physician's fee as reasonable was incomplete. While the commissioner considered the physician's written opinion about the reasonableness of his fee, the commissioner failed to analyze the typical fee charged for such an examination in the local area where the examination was conducted, as required by the 2017 amendment to the statute. Consequently, the court remanded the case for further fact-finding on the issue of the reasonableness of the fee based on the typical fee charged in the local area.Thus, the Supreme Court of Iowa affirmed in part and vacated in part the decision of the Court of Appeals and affirmed in part, reversed in part, and remanded the judgment of the District Court. View "Mid American Construction LLC v. Sandlin" on Justia Law

The case concerns Sandra Selden, an employee at the Des Moines Area Community College (DMACC), who alleged that she was a victim of illegal wage discrimination based on sex and wrongful retaliation. Selden discovered that a male colleague was receiving a higher salary for the same job. When her employer did not act on her complaint, attributing the pay gap to the male employee's greater seniority and initial higher salary because of his relevant experience, Selden filed a civil rights complaint. She also applied for a supervisory position, but her application was screened out due to her lack of required educational qualifications. The case went to trial and the jury awarded damages to Selden on both claims. DMACC appealed the decision.The Supreme Court of Iowa reversed the lower court's decision, holding that the record did not contain substantial evidence of an illegal pay practice. The court found that the pay gap was due to gender-neutral factors, specifically a neutral seniority system, and the decision to hire the male employee at a higher rate due to market conditions and his significant experience. The court also found that the retaliation claim was not supported by substantial evidence, as the employer consistently screened out all applicants who lacked the required qualifications. The court concluded that the lower court should have directed a verdict in favor of the defendants and remanded the case for that purpose. View "Selden v. Des Moines Area Community College" on Justia Law

In a workers' compensation case, an employee was injured and sought compensation from her employer and its insurance carrier. The employee failed to provide her expert witness's evidence in a timely manner, serving them only two weeks before the arbitration hearing began. The employer and its insurance carrier objected, arguing that this late submission of evidence was unfairly prejudicial. The deputy workers’ compensation commissioner agreed with the employer and excluded the evidence. This decision was affirmed by the commissioner, but was later reversed on judicial review by the district court. The court of appeals affirmed the district court’s ruling. However, the Supreme Court of Iowa held that the commissioner’s decision to exclude untimely evidence was entitled to deference. The court found that the commissioner did not abuse his discretion by excluding the untimely evidence since the employee had disregarded multiple deadlines and submitted the reports only about two weeks before the hearing. Moreover, the reports were not from the employee’s treating physicians and the vocational report reached a conclusion that no other expert in the case shared. Therefore, the supreme court vacated the court of appeals decision, reversed the district court decision, and remanded the case back to the district court to enter a judgment affirming the commissioner's decision to exclude the untimely evidence. View "Hagen v. Serta/National Bedding Co., LLC" on Justia Law

In this case, the Supreme Court of Iowa was asked to interpret and apply three provisions of the Iowa Code relating to workers' compensation. The plaintiff, Corey Tweeten, worked on his father's farm and sustained a right arm injury on July 25, 2017. He filed a claim for workers’ compensation benefits on January 21, 2020, more than two years after the incident. The defendants, his father's farm and their insurance carrier, appealed a district court order partially granting Tweeten's claim.The Supreme Court was called upon to interpret three provisions of the Iowa Code: (1) whether a compromise settlement between a claimant and the Second Injury Fund precludes further benefits from the employer, (2) whether the discovery rule tolls the statute of limitations for filing a claim for workers’ compensation benefits, and (3) how amendments to the Iowa Code affect reimbursement for independent medical examinations.The Supreme Court of Iowa held that the compromise settlement between Tweeten and the Second Injury Fund did not bar Tweeten's claims against his employer and their insurance carrier. The Court reasoned that the compromise settlement concerned a dispute over whether a previous injury triggered the Second Injury Compensation Act, separate from the claim against the employer for the current injury. Therefore, the compromise settlement did not bar the separate and distinct claim against the employer.Regarding the second issue, the Court ruled that the discovery rule as previously applied by the courts did not survive the 2017 revisions to the relevant section of the Iowa Code. The Court held that the two-year statutory period begins to run when the employee knows or should know that an injury is work-related, without regard to whether the injury is also serious enough to be compensable. As such, the plaintiff's claim was time-barred, as he knew he had a right-arm injury that was work-related more than two years before he sought benefits.Finally, the court held that the plaintiff was not entitled to reimbursement for the independent medical examination under Iowa Code section 85.39, since the injury for which he was examined was not compensable.The court reversed the lower court's decision and remanded the case for further proceedings. View "Tweeten v. Tweeten" on Justia Law

In this case, Scott Olson, an employee of BNSF Railway Company, sued the company under the Federal Employers' Liability Act, seeking damages for injuries he sustained in a workplace accident. A jury found in favor of Olson and awarded him significant damages. The railway company appealed, alleging three specific instances of error by the district court. The Supreme Court of Iowa vacated the decision of the court of appeals, which had granted a new trial, and affirmed the district court's judgment. The court held that the railway company did not properly preserve its challenge to the verdict form for appeal, as the company had failed to object to the form until after the jury returned its verdict. The court also ruled that the district court did not err by allowing Olson to present new negligence claims during the trial that were not alleged in the pleadings or identified during discovery, as the company was clearly on notice that Olson alleged that the company failed to reasonably train all employees as one of the specific allegations of negligence at trial. Lastly, the court found that the company was not prejudiced by Olson's counsel's alleged misconduct during his rebuttal closing argument. View "Olson v. BNSF Railway Company" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that an Employer's refusal to collect dues from Union members' paychecks was a breach of certain collective bargaining rights and awarding money damages to Union, holding that there was no error.Union brought suit against Employer alleging that Employer breached its contracts by failing to deduct dues. The district court granted summary judgment in favor of Union as to Employer's liability for breach of contract for refusing to deduct dues. After a bench trial on the issue of damages the court awarded $1,046,835 to Union. The Supreme Court affirmed, holding (1) Employer breached the contracts' written terms by failing to collect dues; and (2) the money damages remedy was appropriate and without legal error. View "UE Local 893/IUP v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Desira Johnson, a teacher at the West Des Moines Community Schools (the District), was not subject to individual liability under the Iowa Civil Rights Act (ICRA) on Plaintiff's claim of constructive discharge, holding that there was no error.Plaintiff, a teacher's associate who worked with special education students in the District, sued the District and Johnson, alleging that Johnson engaged in racial discrimination, leading to Plaintiff's constructive discharge in violation of the ICRA. The jury returned a defense verdict in favor of the District. The Supreme Court affirmed, holding (1) the district did not err in overruling Plaintiff's Batson challenge to Defendants' peremptory strike of the only Black potential juror; (2) the district court did not err in granting Johnson's motion for directed verdict for correction of errors at law; and (3) Plaintiff was not entitled to relief on her allegations of error in the district court's evidentiary rulings. View "Valdez v. West Des Moines Community Schools" on Justia Law